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Vande Zande v. State of Wisconsin Department of Administration | 44 F.3d 538 (7th Cir. 1995)

The Americans with Disabilities Act requires that employers reasonably accommodate employees with disabilities. Vande Zande versus State of Wisconsin Department of Administration considers what workplace modifications the employer must provide.

Lori Vande Zande handled clerical duties for the Wisconsin department of administration. Vande Zande was paralyzed from the waist down and used a wheelchair. The prolonged pressure of a seated position frequently caused her to suffer skin and tissue injuries, known as pressure ulcers. Sometimes, treating the pressure ulcers required her to stay home for weeks at a time.

Upon Vande Zande’s request, the department took numerous steps to accommodate her paralysis. It modified bathrooms, installed a step ramp, and provided adjustable office furniture and a cot. The department also rearranged her schedule for medical appointments and granted other requests.

However, the department rejected two requests for accommodation. During an 8-week bout with pressure ulcers, Vande Zande needed to stay home. The department allowed her to work from home but denied her request for a desktop computer that would’ve enabled her to complete her full hours remotely. Even without the desktop computer, Vande Zande completed all but 16 1/2 hours remotely during the 8-week period. She took sick leave to cover the remaining hours.

The department also rejected Vande Zande’s request to lower the counter and sink height in the employee breakroom. It would’ve cost $150 to lower the sink and counter two inches, making them wheelchair accessible. The department opted to install a separate wheelchair height counter and instructed Vande Zande to use the bathroom sink instead of the breakroom sink.

Vande Zande sued the department, claiming it failed to reasonably accommodate her disability. The district court held that the department complied with its statutory duty of reasonable accommodation. Vande Zande appealed to the Seventh Circuit.

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